Klug Law Office PLLC provides tax counsel and legal representation to clients throughout the United States and around the world.  Our office is focused on delivering superior tax planning advice and resolving complex tax disputes in the most effective and efficient manner.

Are unresolved tax problems interfering with your ability to conduct your business, perform the duties of your job, or are they affecting your personal life?

tax litigation attorneyIt is common for taxpayers to procrastinate or even ignore dealing with their unresolved tax issues because they have neither the time nor the experience to resolve them.  Ignoring the tax issues will compound the problem further. By delaying a response and action, you may be sacrificing your rights as a taxpayer. Many actions are under strict time constraints, allowing 30-90 days to respond or risk having liens and levies imposed.

Although most tax disputes are resolved through the IRS audits and appeals procedures, if a favorable result cannot be achieved administratively, the taxpayers have the right to litigate their cases through the federal court system.  Our clients include corporations, partnerships, trusts, estates, individuals, high net worth individuals, and other businesses in the United States and around the world.

 

Tax Audit

tax litigation attorney washington dcAn IRS audit can be extremely time-consuming and financially burdensome for a taxpayer.  The IRS will ask taxpayers questions in order to further the IRS’ position, not necessarily aimed at the correct result.  Hiring an experienced attorney will provide the taxpayer with an advocate for their position to deal with the IRS. Working with an attorney will stop the IRS from directly asking the taxpayer questions on difficult tax issues that have significant consequences. Klug Law Office PLLC represents clients from tax audit notice to resolution or litigation if needed.

 

Tax Litigation

Taxpayers who are in the middle of a federal or State income tax controversy need skilled legal counsel to represent their position.  Klug Law Office PLLC is experienced in representing businesses, individuals, and working with their accountants to resolve tax disputes with Federal, State, and local jurisdictions.  We utilize our experience in selecting the strategies that are essential in obtaining the most favorable results.

It is important to select the proper forum for IRS tax litigation:

  • United States Tax Court:  Most federal tax cases are heard in the United States Tax Court.  The US Tax Court is a court that only hears tax cases. One of the biggest benefits of this forum is that taxpayers are not required to pay the tax assessment before litigation.  Appeals from the US Tax Court are made to the United States Circuit Court of Appeals.
  • United States District Court:  In order to bring a case before a US District Court, taxpayers must exhaust all IRS administrative remedies and prepay the disputed tax deficiency.  The US District Courts are the only venue in which taxpayers may try their case before a jury. Appeal of a decision by a district court must be made to the Circuit Court of Appeals for the Circuit in which the district court lies.
  • United States Court of Federal Claims:  This court can be another favorable forum for taxpayers who pay the disputed tax and sue for a refund.  

Klug Law Office PLLC handles most types of IRS tax disputes including:

  • Voluntary Disclosures:  The voluntary disclosure program allows taxpayers that may have unpaid tax liability or an unfulfilled filing requirement, to disclose their liability voluntarily.  Our approach allows the taxpayer to fulfill the obligations and prevent the imposition of severe penalties in most cases.
  • Responsible Party Assessment and Defense:  Taxing authorities impose severe penalties on individuals who are directly responsible for the nonpayment of trust fund taxes that include sales taxes and payroll taxes.  Our office will assess the taxpayers level of responsibility and defend their position. It is prudent to contact us as soon as possible once notification arises since time constraints are imposed in responding to these assessments.
  • Audit Defense Services:  Many taxpayers do not realize that they have the right to be represented by professionals who are experienced in handling tax audits.  It is not necessary for taxpayers to personally appear before taxing authorities. Our approach is grounded in extensive preparation and research throughout every stage of the audit process, enabling the best results possible.
  • Deferred Payment Arrangements:  Upon receipt of an assessment or bill, taxpayers may believe that full payment must be made within a short period of time.  This is not always the case. Our office will negotiate on the taxpayer’s behalf to institute a liberal payment arrangement that better suits the taxpayer’s disposable income flow.
  • Penalty Abatement Requests:  Taxpayers believe that once a penalty is assessed it is due and payable.  Often, penalties are assessed in error or calculated incorrectly. Our office will determine the reason for the penalty assessment and verify calculations.  If reasonable cause exists, we will pursue an action that generally results in an abatement of the penalties.
  • Offshore Account/Foreign Bank Account Reporting (FBAR)
  • Foreign Trust and Estate Reporting
  • Foreign Business Reporting
  • Employment Tax Disputes
  • Trust Fund Recovery Penalty